March 18, 2003

At the 75 day mark

At the 75 day mark for 12/31 companies – which will be next year’s 10-K deadline – over 1000 companies have already filed their 10-Ks. Considering that there are slightly less than 10,000 companies with 12/31 year-ends, this is a sizable percentage.

On the SEC’s website – under “Regulatory Actions” there is a new section called “PCAOB Rulemaking.” So far it only includes proposed Bylaws for the Public Company Accounting Oversight Board – not the proposals the PCAOB has issued which is available on its website. The SEC’s PCAOB portal is at The PCAOB’s website is at

For subscribers, we have posted model Pre-Approval Policies for Non-Audit Services from Wachtell Lipton and Ernst & Young at

We also have posted sample disclosures from companies that have significant deficiencies and material weaknesses in their internal controls at